Regulatory Considerations for the Potential Use of a Multi-Stage Validation Testing Approach to Support Human Factors Engineering Technical Reviews for Proposed Nuclear Power Plant Control Room Design Modifications

Abstract

Traditionally, integrated system validation (ISV) testing for proposed nuclear power plant control room design changes has been completed prior to the U.S. Nuclear Regulatory Commission (NRC) approving the proposed change. This, however, can pose scheduling challenges for proposed changes to operating facilities. The NRC is therefore considering possible alternatives for licensees to provide the human factors engineering validation information necessary to demonstrate reasonable assurance of safety for proposed design changes. One such alternative could be the use of early-stage testing results from a multi-stage validation (MSV) program. If early-stage results, along with other design considerations, can provide sufficient supporting information, the NRC may be able to make a safety determination for a proposed design change prior to the completion of ISV testing. Licensees proposing such an approach should consider available industry standards discussing MSV, in conjunction with existing NRC guidance where applicable, when developing their validation program and establishing success criteria. The NRC intends to engage in future discussions with stakeholders regarding the potential development of additional NRC-endorsed guidance on the use of MSV to support proposed changes to existing facilities, as well as designs for new reactor control facilities.